Legal Question in Administrative Law in California

Re: Why did the Respondent's attorney object to my argument?

Ordinarily, an objection must state a ground. Further, objections are usually addressed to material offered as evidence, not purely legal argument.

My suspicion is that your opponent is making objections to your use of facts, or alleged facts,in your legal argument without proper support from the record.

I understand that your matter is a petition for a writ of mandate, which may involve somewhat different rules, but ordinarily if a brief, motion, etc. contains, alleges, refers to, etc., facts, then the place where those facts appear in the record must be cited in the brief.

For example, "My client drove through the light while it was green. (Police Report, pgh. 5(d). However, the speed limit was 35 MPH (Arraignment testimony of Officer Jones, page 2, line 16-18). The weather was rainy and cold (Daily News, p. 33)."

Writing a legal argument and bringing up facts, even ones "everyone knows," without citing where those facts are shown in the record of this case, or of which the Court must take judicial notice, leaves your argument open to challenge for using "facts" not supported by the record.

This is why attorneys attach declarations under oath made by their cleitns or favorable witnesses to their motions and briefs, to provide a basis for factual assertions made in a presentation to the court.

Attorneys are presumed not to know and therefore to be unable to assert any facts on their own. An in pro. per. litigant has the same problem. You are there in two capacities: principal and advocate. When you write as advocate you cannot simply assert what you know as principal in the same breath. You need to attach it as a deposition, under oath, then work it in.

I have no idea if this is what has happened here, but it it is among the possibilities. Using facts without foundation.